Limited inspection power under company law cannot become a roving investigation, but may include calls for explanations and assistance.

Section 209A inspection under the Companies Act, 1956 is confined to books of account, ledgers, related documents and vouchers, read in context as records bearing the character of accounts. The power cannot be used as a substitute for investigation under section 237 or as a roving enquiry into every aspect of the company's affairs. At the same time, once the relevant books and papers are inspected, the authority may call for statements, information, explanations and assistance within the section's scope. The result is a limited, regulated inspection power rather than unrestricted investigative authority.

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Issues: Whether the power of inspection under section 209A of the Companies Act, 1956 is confined to books of account and related records, and whether it can be used to compel a wider roving enquiry into the company's affairs.

Analysis: The inspection power under section 209A was held to be limited in scope. The expression used in the provision was read in context, and the documents open to inspection were treated as those having the character of books of account and allied records. The Court distinguished inspection under section 209A from investigation under section 237 of the Companies Act, 1956, and accepted that the inspecting authority could not, under the guise of inspection, conduct an unrestricted enquiry into all aspects of the company's affairs. At the same time, the Court accepted that after inspection of the relevant books and papers, the authority could require statements, information, explanations, and assistance in accordance with the section.

Conclusion: The inspection power was held to be restricted to relevant books, ledgers, documents, and vouchers, and not to extend to a roving investigation into the company's affairs; the petitioners obtained limited relief by way of directions regulating the inspection.

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